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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />excavation and removal of a quantity of the coal for disposal within the coal waste disposal site, as approved in <br />TR-22. In addition, excavation was underway for construction of the postmine "cattle trail" along the original <br />power line alignment. <br />The upper boundary of the "highwall crest reduction area" had been staked in place in accordance with the <br />approved reclamation plan. The crest reduction perimeter was observed and authorized by Bruce Fowler of <br />BLM, as required by the reclamation plan, during the site inspection on the morning of May 24. Written <br />confirmation of BLM acceptance of the staked disturbance limit in this location was subsequently provided by <br />BLM. Topsoil will be pushed off the crest area and will be segregated from underlying material as the first step <br />in the crest reduction grading. Pinyon and juniper slash will also be segregated and distributed across the final <br />reclamation slope prior to seeding. All areas to be seeded will be extensively roughened by track-hoe bucket <br />gouging, with the exception of the sides of the permanent road and certain locations along the reclaimed <br />powerline corridor, which will be loosened by chisel or track-hoe tooth scarification prior to seeding. <br />Processing Waste <br />Waste material in the disposal cell had recently been graded relatively level. Waste material in the disposal is <br />graded and compacted in maximum two foot lifts, in accordance with the approved plan. In accordance with <br />recently approved TR-22, final reclamation of the waste disposal area will occur in association with the current <br />Munger Mine reclamation project, much earlier than originally anticipated. TR-22 allows for hauling a portion of <br />the coal material currently stored at the Munger mine bench, for final disposal in the waste disposal site, and that <br />operation is expected to occur very shortly. <br />Grasses seeded on the refuse cover sail stockpile last summer have recently initiated spring growth. The cover <br />soil pile appears stable, with no evidence of slumping or rills and gullies. The cover material will be excavated <br />and placed over the final graded, compacted coal waste material within the next several weeks. The footprint of <br />the current cover material stockpile will be regraded, topsoiled, extensively roughened, and seeded. <br />Support Facilities <br />Removal of the powerline up Munger Canyon to the portal area had been initiated prior to the inspection. A <br />dozer had been used to remove the poles and pull out the cable. In some areas, vegetation had been only <br />minimally disturbed, and will recover without further remediation. However, in various locations along the <br />route, dozer operations had disturbed the soil surface, and in these areas scarification of the soil and <br />reseeding will be warranted. Further, in locations where the route crossed ephemeral drainages, the <br />ephemeral channels had been partially or completely filled in. Where this occurred, the original channel <br />configuration in the disturbed area will need to be restored and the locations will need to be reseeded. <br />The "cattle trail" from the canyon bottom up through the reclaimed portal bench area will also need to <br />be seeded during final reclamation operations. <br />Topsoil <br />The topsoil stockpiles on the lower road and at the waste disposal area, and the "dirt stockpile' on the mine <br />bench (which will be used as reclamation topdressing) are well vegetated and stable. Material from these <br />stockpiles will be used for final reclamation topdressing at the portal area and waste disposal area. Live <br />whitetop plants were in flower on and immediately adjacent to these soil stockpile areas. In order to prevent <br />spread of whitetop seed to the reclaimed areas during reclamation operations, all remaining whitetop <br />plants with flowering stalks that are growing on, or in the immediate vicinity of the stockpiles and <br />reclamation sites, should be cut down, bagged, and removed from the site prior to further reclamation <br />disturbance. <br />5 <br />